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Abstract

Wengler indicates that the substantial relationship test will be applied to both benign and invidious gender classifications. The Court has rejected what appeared to be a result orientation that enabled it to characterize a gender classification as benign or invidious and hold it constitutional or unconstitutional on that basis. With symmetry established in the level of scrutiny, the Court has left little room for manipulating results-except to the extent it recognizes new important governmental purposes to support a substantially related classification-and has, consequently, given increased predictability to future consideration of gender-based discrimination cases.

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